LEGAL PRINCIPLE: CIVIL PROCEDURE – Jurisdiction – Territorial Jurisdiction – Court’s Competence to Adjudicate on Land Outside Its Territorial Limits
PRINCIPLE STATEMENT
A court is competent when the subject matter of the case is within jurisdiction and there is no feature in the case which prevents the court from exercising its jurisdiction. As the land in dispute is outside the jurisdiction of Area Court No.1, Zaria City which has no power to hear and determine the suit or exercise any judicial power over it, the decision reached by it is a nullity.
RATIO DECIDENDI (SOURCE)
Per Ogwuegbu, JSC, in Galadima v. Tambai & Ors (2000) NLC-2171994(SC) at p. 7; Paras A–B.
"A court is competent when the subject matter of the case is within jurisdiction and there is no feature in the case which prevents the court from exercising its jurisdiction. As the land in dispute is outside the jurisdiction of Area Court No.1, Zaria City which has no power to hear and determine the suit or exercise any judicial power over it, the decision reached by it is a nullity."
EXPLANATION / SCOPE
Territorial jurisdiction is fundamental—a court cannot adjudicate on land outside its designated territorial limits. Such a court lacks competence entirely, rendering its proceedings and decisions nullities. This rule ensures that courts exercise power only within their lawful geographic boundaries, respecting the territorial limits established by their enabling statutes. Parties cannot confer jurisdiction by consent where territorial limits are exceeded. Any judgment on land outside the court’s territory is void ab initio and cannot be enforced or validated.